COUNT 1 RESPONDENT FAILED TO DEVELOP AND FOLLOW A WRITTEN WASTE ANALYSIS PLAN. COUNT 2 RESPONDENT HAS FAILED TO MAINTAIN DOCUMENTATION OF INSPEC- TIONS FOR 3 YEARS FROM THE DATE OF INSPECTION. COUNT 3 RESPONDENT FAILED TO MAINTAIN THE REQUIRED DOCUMENTS AND RECORDS AT THE FACILITY. COUNT 4 RESPONDENT FAILED TO MAINTAIN THE REQUIED AGREEMENTS WITH LOCAL AUTHORITIES OR DOCU LOCAL AUTHORITES' REFUSAL TO MAKE SUCH AGREEMENT. COUNT 5 RESPONDENT FAILED TO PREPARE AN ADEQUATE CONTINGENCY PLAN. PROPOSED PENALTY OF $13,500. COMPLIANCE ORDER UPON RECEIPT OF THIS COMPLAINT AND COMPLIANCE ORDER, RESPONDENT SHALL CEASE AND DESIST ON-SITE STORAGE, TREATMENT AND DISPOSAL OF HAZARDOUS WASTE. RESPONDENT MAY NOT CONDUCT TREATMENT, STORAGE AND DISPOSAL OPERATIONS UNTIL IT RECEIVES A RCRA PERMIT.